Intermediary services not amount to FTS & not taxable under India-Sweden DTAA

Bombardier Transportation Sweden AB Vs DCIT (ITAT Delhi) Conclusion: Payment of consideration would be regarded as ‘fee for technical/included services’ only if the twin test of rendering services and making technical knowledge available at the same time was satisfied. Intermediary services rendered by assessee did not make available any technical knowledge, skill etc to BTIN and BTIN was not a equipped to apply technology contained in services rendered by assessee. Therefore, the intermediary services provided by assessee to BTIN did not tantamount to FTS and accordingly, should n...